Privacy Notice

This privacy policy sets out how ICP uses and protects any information that you give ICP when you use this website. ICP is committed to ensuring that your privacy is protected. Should we ask you to provide certain information by which you can be identified when using this website, then you can be assured that it will only be used in accordance with this privacy and cookies statement. ICP may change this policy from time to time by updating this page. You should check this page from time to time to ensure that you are happy with any changes. This policy is effective from May 25th, 2018.

Who We Are

ICP gather and process your personal information in accordance with this privacy notice and in compliance with the relevant General Data Protection Regulation and laws. This notice provides you with the necessary information regarding your rights and our obligations, and explains how, why and when we process your personal data.

ICP is a trading name of Cadran Services Limited, our registered office is at Bramah House, 65-71 Bermondsey Street, London, UK SE1 3XF and we are a company registered in England and Wales under company number 02173193. We are registered on the Information Commissioner’s Office Register, and act as both a Data Controller and a Data Processor when processing your data, depending on the circumstances. Our designated Data Protection Officer/Appointed Person is Martin Handyside who can be contacted at the address above or via email at martin.handyside@icpnet.com.

Information That We Collect

ICP processes your personal information to meet our legal, statutory and contractual obligations and to provide you with our products and services. We will never collect any unnecessary personal data from you and do not process your information in any way, other than as specified in this notice.

Most of the personal information we process is provided to us directly by you for one of the following reasons:

• You have made an enquiry to us
• You have made an information request to us
• You have attended an event and passed contact details to one of our employees
• You subscribe to our marketing communications/ e-newsletter
• You have applied for a job with us.
• You are representing your organisation as a client or supplier.

We also receive personal information indirectly, in the following scenarios:

• When acting on behalf of our clients in the normal performance of our duties
• Identifying relevant business contacts to approach to offer our services to them (under our legitimate business interests.)

How We Use Your Personal Data (Legal Basis for Processing)

ICP takes your privacy very seriously and will never disclose, share or sell your data without your consent; unless required to do so by law. We only retain your data for as long as is necessary and for the purpose(s) specified in this notice. Where you have consented to us providing you with promotional offers and marketing, you are free to withdraw this consent at any time. The purposes and reasons for processing your personal data are detailed below: –

• We collect your personal data in the performance of a contract or to provide a service and to ensure that orders are completed and can be sent out to your preferred address
• We collect and store your personal data as part of our legal obligation for business accounting and tax purposes
• We will occasionally send you marketing information where we have assessed that it is beneficial to you as a customer or prospect and in our interests. Such information will be non-intrusive and is processed on the grounds of legitimate interests

Your Rights

You have the right to access any personal information that we process about you and to request information about: –

• What personal data we hold about you
• The purposes of the processing
• The categories of personal data concerned
• The recipients to whom the personal data has/will be disclosed
• How long we intend to store your personal data for
• If we did not collect the data directly from you, information about the source

If you believe that we hold any incomplete or inaccurate data about you, you have the right to ask us to correct and/or complete the information and we will strive to do so as quickly as possible; unless there is a valid reason for not doing so, at which point you will be notified.

You also have the right to request erasure of your personal data or to restrict processing (where applicable) in accordance with the data protection laws; as well as to object to any direct marketing from us. We do not use your data for automated decision-making.

If we receive a request from you to exercise any of the above rights, we may ask you to verify your identity before acting on the request; this is to ensure that your data is protected and kept secure.

Sharing and Disclosing Your Personal Information

We do not share or disclose any of your personal information without your consent, other than for the purposes specified in this notice or where there is a legal requirement. We use data processors who are third parties who provide elements of services for us. We have contracts in place with our data processors which means that they cannot do anything with your personal information unless we have instructed them to do it. They will not share your personal information with any organisation apart from us. They will hold it securely and retain it for the period we instruct.

Safeguarding Measures

ICP takes your privacy seriously and takes every reasonable measure and precaution to protect and secure your personal data. We work hard to protect you and your information from unauthorised access, alteration, disclosure or destruction and have several layers of security measures in place.

Transfers Outside the EU

Personal data in the European Union is protected by the General Data Protection Regulation (GDPR) but some other countries may not necessarily have the same high standard of protection for your personal data. ICP does not transfer or store any personal data outside the EU; except when you apply for a job in one of our overseas offices, in which case we may pass your details to them.

Legitimate Interests

As noted in the ‘How We Use Your Personal Data’ section of this notice, we occasionally process your personal information under the legitimate interests’ legal basis. Where this is the case, we have carried out a thorough Legitimate Interests’ Assessment (LIA) to ensure that we have weighed your interests and any risk posed to you against our own interests; ensuring that they are proportionate and appropriate.

How Long We Keep Your Data

ICP only ever retains personal information for as long as is necessary and we have strict review and retention policies in place to meet these obligations. We are required under UK tax law to keep your basic personal data (name, address, contact details) for a minimum of 6 years after which time it will be destroyed. Where ICP are the data ‘processor’ to fulfil our client contract, we abide by the client’s own retention policy as they are the data ‘controller’.

Where you have consented to us using your details for direct marketing, we will keep such data until you notify us otherwise and/or withdraw your consent.

Lodging A Complaint

ICP only processes your personal information in compliance with this privacy notice and in accordance with the relevant data protection laws. If, however you wish to raise a complaint regarding the processing of your personal data or are unsatisfied with how we have handled your information, please let us know, (martin.handyside@icpnet.com), we will do our best to rectify the situation. If you are still dissatisfied you have the right to lodge a complaint with the supervisory authority.

Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF

Cookie Notice

How we use cookies:

A cookie is a small file which asks permission to be placed on your computer’s hard drive. The cookie helps analyse web traffic or lets you know when you visit a particular site. Cookies allow web applications to respond to you as an individual. The web application can tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences. We use traffic log cookies to identify which pages are being used. This helps us analyse data about webpage traffic and improve our website in order to tailor it to customer needs. We only use this information for statistical analysis purposes and then the data is removed from the system. Overall, cookies help us provide you with a better website, by enabling us to monitor which pages you find useful and which you do not. A cookie in no way gives us access to your computer or any information about you, other than the data you choose to share with us. You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. This may prevent you from taking full advantage of the website.

Links to other websites:

Our website may contain links to other websites of interest. However, once you have used these links to leave our site, you should note that we do not have any control over that other website. Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting such sites and such sites are not governed by this privacy and cookies statement. You should exercise caution and look at the privacy statement applicable to the website in question.